20180125Petition to Intervene.pdf

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AoNaITTeo TN IDAHO, OREGON, AND WASHTNGToN
CABLE HUSTON.,.ORIGINAL
j c av anagh@c ab I ehusto n. co m
www.cablehuston.com
January 24,2018
Vn FrconnrI, EXPRESS
Diane M. Hanian, Secretary
Idaho Public Utilities Commission
472 W . Washington Street
Boise, ID 83702
Re: Case No. INT-G-17-07
Dear Ms. Hanian:
Please find enclosed for filing with the Commission originals of the following pleadings
(along with 7 copies):
Motion for Limited Admission Pro Hac Vice; and
Petition to Intervene of Northwest Industrial Gas Users
A copy of the Motion for Limited Admission Pro Hac Vice, along with the required fee
and a copy of Certificate of Good Standing, have been delivered via Federal Express to the Idaho
State Bar. Should you have any questions, please give me a call. Thank you.
Sincerely,
J
J. Cavanagh
JJC:lms
Enclosure(s)
cc: Chad Stokes
1.
2.
Suite2000, 1001 SWFifthAvenue,Portland,Oregon9T204-1136 " Phone: [phone] r Fax: [phone] n www.cablehuston.com
Jonathan J. Cavanagh, ISB No. 8609
Chad M. Stokes, OSB No. 004007
Cable Huston LLP
l00l SW Fifth Ave., Suite 2000
Portland, OR 97 204-1 136
Telephone: [phone]
Facsimile: (503) 224-317 6
j c av anagh@cab I ehuston. com
cstokes@cablehuston. com
RECEIVED
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IDi.i"iCI PUBLIC
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ORIGINAL
Attorneys for Northwest Industrial Gas Users
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF
INTERMOUNTAIN GAS COMPANY
FOR THE AUTHORITY TO
IMPLEMENT AN
INFRASTRUCTURE INTEGRITY
MANAGEMENT MECHANISM
CASE NO. INT.G.I7-07
PETITION TO INTERVENE OF
NORTHWEST INDUSTRIAL GAS
USERS
Pursuant to Rules of Procedure 7l through 75 of the Idaho Public Utilities Commission
(ooCommission") Rules of Procedure, IDAPA 31.01.01 .071-.075, Northwest Industrial Gas
Users ("NWIGU") hereby submits this Petition to Intervene in the above-captioned proceeding.
As discussed below, NWIGU has a direct and substantial interest in these proceedings, and
respectfully requests that the Commission grant its intervention.
The name and address of NWIGU as an intervenor in this proceeding is:
Northwest Industrial Gas Users
c/o Edward A. Finklea
Executive Director
545 Grandview Drive
Ashland, OR 97520Phone: [phone]
Facsimile: [phone]E-Mail: [e-mail]
NORTHWEST INDUSTRIAL GAS USERS' PETITION TO INTERVENE - I
Jonathan J. Cavanagh and Chad M. Stokes from the law firm Cable Huston LLP will
represent NWIGU in this proceeding. In addition to Mr. Finklea, all notices, pleadings,
production requests and responses, and other documents related to this proceeding should be
served on NWIGU's attorneys at the following address:
Jonathan J. Cavanagh
Chad M. Stokes
Cable Huston LLP
1001 SW Fifth Ave., Suite 2000
Portland, OR 97204-1 136
Telephone: [phone]
Facsimile: [phone]E-Mail: [e-mail]
cstokes@cablehuston. com
1. NWIGU is a non-profit association comprised of approximately 40 end users of
natural gas with major facilities in the States of Oregon, Washington, and Idaho. NWIGU
members include diverse industrial and commercial interests, including food processing, pulp
and paper, wood products, electric generation, aluminum, steel, chemicals, electronics,
aerospace, and healthcare providers. The association provides an informational service to its
members and participates in various regulatory matters that affect member interests. NWIGU
member companies purchase sales and transportation services from local distribution companies
including Intermountain Gas Company ("Intermountain").
2. On December 18, 20lT,Intermountain applied for authority to implement an
Infrastructure Integrity Management Mechanism ("Application"), along with a proposed rate
schedule.
3. Because NWIGU member companies purchase sales and transportation services
from Intermountain, NWIGU and its members will be impacted by any decision in this
NORTHWEST INDUSTRIAL GAS USERS' PETITION TO INTERVENE - 2
proceeding and therefore have a direct and substantial interest in Intermountain's Application.
NWIGU requests permission to participate in this proceeding as a party as its interest may arise.
4. NWIGU's participation in this proceeding will assist the Commission in resolving
the issues, and will not unduly broaden the issues or delay the proceeding.
WHEREFORE, for the reasons described above, NWIGU respectfully requests leave to
intervene and fully participate with all rights as a formal party in this proceeding.
This Petition is accompanied by a Motion for Limited Admission Pro Hac Vice
requesting admission of Chad M. Stokes to serve as counsel to NWIGU in this proceeding.
Dated ttris 4$aay of January 2018.
submitted,
J J. Cavanagh, ISB No
Chad M. Stokes, OSB No. 004007
Cable Huston LLP
1001 SW Fifth Ave., Suite 2000
Portland, OR 97 204 -l I 3 6
Telephone : [phone]
Facsimile: (503) 224-317 6
j cav anagh@c ab I ehusto n. com
cstokes@cablehuston. com
Attorneys for Northwest Industrial Gas Users
NORTHWEST INDUSTRIAL GAS USERS' PETITION TO INTERVENE - 3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on ,n"{Ourof January 2018 I caused an original and seven
(7) copies of the foregoing to be served upon:
Diane M. Hanian, Secretary
Idaho Public Utilities Commission
472 W . Washington Street
Boise, lD 83702
by mailing via Federal Express the same to the above-named at the last known address(s) as set
forth above and mailing a copy via First-Class Mail to the addresses below.
Ronald L. Williams
Williams Bradbury, P.C.
P.O Box 388, Boise,ID 83701
802 W. Bannock, Suite 900
Boise, lD 83702
Michael P. McGrath
Director, Regulatory Affairs
Intermountain Gas Company
PO Box 7608
Boise,lD 83707
\
J. Cavanagh
NORTHWEST INDUSTRIAL GAS USERS' PETITION TO INTERVENE - 4